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Diverting profits of individuals and close companies to overseas entities – anti-avoidance

Following an announcement at the Autumn Budget in 2017, HMRC has issued a consultation document ‘Tax avoidance involving profit fragmentation’. This contains proposals to prevent individuals and small companies that carry on a trade or profession in the UK from avoiding tax by diverting profits to overseas entities in low-tax, or no-tax, jurisdictions. The arrangements that are under attack involve fragmenting profit that in substance derives from a single UK activity with the result that for tax purposes it arises partly in the UK and partly overseas.
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